Double Taxation Agreement Between Myanmar And Hong Kong
In June 2019, the Royal Government of Cambodia announced the signing of a double taxation agreement (“DBA”) with the government of the Hong Kong Special Administrative Region of the People`s Republic of China (“Hong Kong”), bringing to seven the number of DBAs signed by Cambodia. This agreement brings to seven the number of DBAs signed by Cambodia and contains specific provisions that include: in addition to double tax evasion, the agreement provides for the exchange of information between the two tax authorities in order to implement measures to combat tax evasion, profit transfers and erosion of basic reasons. The previous DBA with China does not apply to Hong Kong or Macau, as each of these territories has its own tax system and is not covered by the tax legislation of the People`s Republic of China. In June 2019, Cambodia and the government of the Hong Kong Special Administrative Region of the People`s Republic of China (Hong Kong) signed a treaty to avoid double taxation and prevent tax evasion. The treaty came into force on January 1, 2020. Taxpayers who wish to use this DBA must prove to the Cambodian General Tax Administration that their business is engaged in actual or significant economic activity in the contracting state. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXTREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT. As a general rule, the DBA discharge is not granted if the company is incorporated exclusively to use the DBA without actual economic activity in the contracting state. Various rules, such as the limitation of social benefit rules, the rules for the abolition of dividends and the anti-Driving rules, have been established to determine the economic beneficiary of the payment. It is advisable to contact your VDB Act tax advisor to verify the status of the beneficial owner of your business before continuing your application.
In addition, Hong Kong airlines flying to and from Cambodia are no longer subject to corporation tax in Hong Kong and Hong Kong-based international shipping companies are entitled to a 50% reduction in tax on income collected in Cambodia. The DTA discharge is not automatic. In accordance with Instruction 4084 issued in March 2018, taxpayers who wish to apply reduced withholding tax rates under a DBA must apply to the General Ministry of Taxation (GDT). The application must be supported by evidence of the tax resident status of the offshore party and the transaction subject to the reduced rate. Cambodia has reduced the withholding rate on interest, dividends, royalties and royalties on technical services provided to Hong Kong residents, as shown in the table below. A summary of the essential features of the seven DBAAs is as follows: ACCORD FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH AFGHANISTAN While the government and government of Afghanistan have reached an agreement for this DBA, Hong Kong is defined as any place where the tax laws of the Hong Kong Special Administrative Region of the People`s Republic of China apply. The Hong Kong DBA contains provisions similar to other DBAs, as follows: . . AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH ALBANIA THE GOVERNMENT OF INDIA WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL Companies that already have transactions with Hong Kong companies are invited to advise us immediately on the steps they must take to be able to benefit without delay from the DTA relief services immediately after the DBA comes into force in Cambodia-